Tottenham Hotspur football training facility, Bulls Cross, Enfield

planning report PDU/1330a/01
                                                                                      7 June 2006

        Tottenham Hotspur football training facility,
                               Bulls Cross, Enfield
                                                         in the London Borough of Enfield
                                                     planning application no. TP/06/0735

Strategic planning application stage 1 referral Town and Country Planning Act 1990
(as amended); Greater London Authority Act 1999; Town & Country Planning (Mayor of London)
Order 2000

The proposal
The development of a football training centre which provides facilities for Tottenham Hotspur
Football Club’s first team squad and the Club’s youth academy. These facilities comprise indoor and
outdoor sports pitches, changing facilities, gym area, medical, physiotherapy and hydrotherapy
treatment rooms, lounge and reception areas, dining and relaxation facilities, administrative, storage
and maintenance areas and education class rooms.

The applicant
The applicant is Tottenham Hotspur Football Club, and the architect is KSS.

Strategic issues
The applicant has made a robust argument demonstrating that very special circumstances exist
to warrant inappropriate development in the Green Belt but a stronger commitment to delivering
a wider package of community benefits is sought. The football training facilities are of a striking
design, reflecting the professional, Premier League status of the Club and the development has
been sensitively designed and buildings positioned on the site to minimise impacts on the
openness of the Green Belt. The development of world-class sporting facilities supports the
development of London as a world city. The scheme responds appropriately to the historic
context and offers an opportunity to reinstate historic hedgerows to enhance the setting of a listed
building. Two sustainable energy options are proposed for the scheme both of which will provide
decentralised energy generation and 10% from renewables. However, conditions are needed to
ensure further detailed analysis and to secure their implementation. Green roofs and sustainable
urban drainage systems have been incorporated to deliver the Mayor’s sustainability objectives
but as the site is remote and has limited public transport options a much stronger green travel plan
is needed to encourage alternative more sustainable methods of transportation. TfL also objects to
the level of parking and seeks dual use of the parking facilities. Further analysis of the impact of
the development on the A10 junction is also sought.
That Enfield Council be advised that the principle of the development on Green Belt may be
acceptable given the robust ‘very special circumstances’ argument put forward. However, a more
tangible commitment to delivering a more comprehensive package of community benefits is
required. A reduction in parking and an exemplary green travel plan are also required to
demonstrate that the proposal meets the Mayor’s transportation/sustainability policies.
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1      On 20 April 2006 Enfield Council consulted the Mayor of London on a proposal to develop
the above site for the above uses. Under the provisions of the Town & Country Planning (Mayor of
London) Order 2000 the Mayor has the same opportunity as other statutory consultees to
comment on the proposal. This report sets out information for the Mayor’s use in deciding what
comments to make.

2       The application is referable under Category 3D of the Schedule of the Order 2000:
“Development – (a) on land allocated as Green Belt or Metropolitan Open Land in the development
plan, in proposals for such a plan, or in proposals for the alteration or replacement of such a plan;
and (b) which would involve the construction of a building with a floor space of more than 1000
square metres or a material change in the use of such building.”

3       If Enfield Council subsequently decides that it is minded to grant planning permission, it
must first allow the Mayor an opportunity to decide whether to direct the Council to refuse

4      The environmental information for the purposes of the Town and Country Planning
(Environmental Impact Assessment) (England and Wales) Regulations 1999 has been taken into
account in the consideration of this case.

5     The Mayor of London’s comments on this case will be made available on the GLA website

Site description
6       The site is located just south of the M25 and Whitewebbs Lane and west of the A10 and
Bulls Cross Road. It is an irregular shaped block and has a total area of approximately 57.7 acres.

7       Approximately 21.5 acres of the land contains private sports fields. These fields are
currently leased to Tottenham Hotspur for youth academy matches. The proposed site for the first
team and academy training facility occupies the grounds (including the sports fields) to the west of
the Grade II listed Myddleton House and the agricultural fields beyond, which form part of the
northern reaches of the Forty Hall Estate. The area immediately west of Myddleton House
contains an existing 1960’s sports pavilion and tennis courts which would be removed as part of
the proposal.

8     Myddelton House estate contains a number of Grade II listed buildings and structures. The
Myddleton House gardens are included on the English Heritage Register of Historic Parks and
Gardens, as Grade II historic landscapes.

9       The remaining 34.5 acres are in agricultural use and are in the ownership of Enfield Council.
An existing mature hedge separates the agricultural land from the sports fields and other mature
trees are dotted around the playing fields. The site is bounded to the south by land within the
Forty Hall Estate, in particular the Forty Hall Estate woodland (identified as a Site of Importance
for Nature Conservation) and further south, Forty Hall, a Grade I listed building. Land to the south
and east is mainly residential with more open country to the west and north. The eastern end of
the site falls within the Forty Hill Conservation Area.

10    Existing access to the playing fields and pavilion is via a shared access road off Bulls Cross
Road. This road also serves the Lee Valley Regional Park Authority Offices (at Myddelton House).

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11     The topography of the site is generally flat but the land slopes away gradually to the south
towards Turkey Brook.

Details of the proposal
12       The proposed development comprises the football training centre providing training
facilities for the youth academy and the Tottenham Hotspur first team, and is located on existing
privately owned sports fields and agricultural land immediately west of Myddleton House.

The football training centre

13       The key facilities of the youth academy within the football training centre are:

     •   Internal artificial pitch practice area (70 metres x 50 metres).
     •   Education areas and classrooms.
     •   Changing facilities for full and part time students.
     •   Gym facilities and associated medical, hydrotherapy and physiotherapy treatment areas.
     •   Lounge and reception area.
     •   Relaxation and dining facilities.
     •   Office areas.
     •   7 x outdoor grass training and match sports pitches (one floodlit).
     •   1 x artificial sports pitch (floodlit).

14       The key facilities of the first team are:

     •   4 x outdoor grass training and match sports pitches (no floodlighting).
     •   Fitness and rehabilitation gym.
     •   Hydrotherapy pool, swimming pool and medical rooms.
     •   Changing rooms.
     •   Relaxation and dining facilities.
     •   Administration office.
     •   Press and media room.

15       The indoor youth academy facilities, first team facilities and community programme
facilities are co-located within the football training centre building. This building is positioned
centrally on the site, near the northern boundary and gains access via a proposed driveway off
Whitewebbs Lane. Permanent parking provision for 122 vehicles is proposed. 58 spaces for the
first team players would be provided and would be separate from the remaining 64 academy
spaces. Coach parking for a maximum of five coaches is also proposed. An area for overflow
parking (90 spaces) is also proposed along the western boundary and will be formed of structured
reinforced grass. Access to the site and first team parking area is controlled via security gates and
a manned security control point is located adjacent to the entrance drive.

16     The building is split over three levels including a semi basement indoor sports pitch, with
the central reception area, press office, changing rooms, gymnasia, hydrotherapy pool and
treatment rooms at ground floor level, and other uses including dining areas, relaxation rooms,
educational space and administrative spaces at first floor level. The building has a total footprint
of approximately 7,738 sq.m. whilst the total floor area (including ancillary buildings such as the
grounds maintenance shed and security lodge) comprises 12,456 sq.m.

17      The grass sports pitches are laid out to the east and west of the building with the artificial
pitch immediately south of the building. Two of the sports pitches are floodlit. A grounds

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maintenance and storage facility (605 sq.m.) is proposed in the south-western corner of the site
immediately adjacent to the Forty Hall Estate Woodland.

Case History
18     The current application follows a previous planning application for a similar scheme at the
same location. That application, lodged with Enfield Council in October 2005, was withdrawn in
response to concerns raised by both the Council and the GLA. The earlier scheme was not formally
presented to the Mayor. The principal differences between the current scheme and the previous
proposal are:

    •   The application site has been reduced in size to exclude the Bulls Cross Sports Ground on
        the eastern side of Bulls Cross Road, where it was previously proposed to develop a
        separate, dedicated community sports facility.

    •   The amount of floor space has been reduced as a result of reductions in the scale of the
        football training centre and the removal of the community sports facility from the
        application. The total floor space reduction is 2,810 sq. m.

    •   The design of the football training centre has been significantly altered in response to
        concerns raised by the GLA and Enfield Council.

Need for new facilities

19       Tottenham Hotspur Football Club currently have a combined first team and academy
training facility at Spurs Lodge, Chigwell, just outside London. The facilities at this site are
outdated and of low quality, particularly in terms of fitness training and medical support. Given the
lack of space and the poor standard of accommodation at Spurs Lodge these facilities are also
supplemented by facilities located on separate sites. Training is split between Spurs Lodge
(Chigwell), White Hart Lane (Tottenham), and Myddleton House (Enfield) and three privately
owned gyms (Esporta, Repton Park, David Lloyd, Chigwell and Holmes Place, Chigwell) are also
utilised by the Club for weight training, swim training and hydrotherapy.

20      The Club’s youth academy currently operates under a temporary license granted by the
Football Association from the same three locations; White Hart Lane, Spurs Lodge and Myddleton
House. These facilities fail to satisfy the Football Association’s licensing requirements in a number
of respects including:
    •   Insufficient grass pitches for the number of age-bands within the academy.
    •   Inadequate medical and examination areas; inadequate changing facilities for students,
        visitors and staff.
    •   Inadequate homework and study areas.
    •   No provision of indoor training facilities of an appropriate size.

21      The Club has been granted an extension to the temporary license as a result of the length
of time it has taken to find a suitable alternative site for establishing the required facilities. If the
Club is unable to satisfy the licensing requirements it will lose its academy status.

22       GLA and Enfield officers visited the existing facilities at Spurs Lodge and also visited the
first team training facilities at Arsenal Football Club to compare the respective quality of these
facilities. The need for new facilities was clearly apparent after this site visit.

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23       The proposal would concentrate activity on one site rather than being dispersed over
several sites as they are currently, thereby reducing the need for staff and players to travel between
the Club’s different training locations. Combined facilities would enable the training and
development of both professional players and academy members to take place where medical
assessment and treatment facilities are located at the training ground, therefore resulting in an
enhanced and safer training environment for players. The proposal enables development of new
facilities not currently available at Spurs Lodge or White Hart Lane, including specialist fitness and
rehabilitation gymnasia, hydrotherapy and medical treatment rooms. These new facilities would
enhance the standard of training and support currently available to Tottenham Hotspur, to a level
that is comparable with the best professional English and European clubs.

24       The need for new facilities is clear. Combining the facilities on a single site an appropriate
approach as it avoids duplication of facilities and limits the physical impacts of development to a
single site rather than to two (or more) sites. GLA officers requested the applicant to undertake an
analysis of the nature of other Premiership and Championship League facilities, to provide a
benchmark against which this development could be measured. This analysis demonstrated two
things; firstly, that the provision of professional football training facilities in Green Belt locations is
relatively commonplace (Arsenal, Aston Villa, Birmingham City, Chelsea, Manchester United,
Sunderland, Tottenham Hotspur, West Bromwich Albion and Wigan Athletic all have training
facilities within the Green Belt); and secondly, that there is a preference for professional football
clubs to co-locate and combine their facilities wherever possible. Fourteen out of the twenty
Premiership clubs operate out of one site, and nine of the fourteen clubs have their first team and
academy facilities within a combined building.

Alternative site search

25      An extensive site search to identify a suitable location for new combined facilities was
undertaken before this site was selected. The search commenced in 1998 and examined a number
of options: the potential for expansion of existing facilities at Spurs Lodge; the relocation of only
the academy to a separate site; and the relocation of all the Club’s professional training and
development activities to a single site.

26      The potential for expansion of the existing facilities at Spurs Lodge was explored and
discounted due to the very particular physical constraints of this site. Expansion immediately east
was constrained by the M11 but a variety of other expansion options were explored. Thames Water
owns the land south of Spurs Lodge. An assessment undertaken by the applicant confirms that
ground conditions to the south of the site (as a result of the previous use of the land for a Thames
Water treatment facility) were unsuitable for expansion. Land to the south east of Spurs Lodge,
owned by Essex County Council, was also found to have geotechnical constraints as a result of the
historic use of the site for landfill, rendering it unsuitable for use. Finally, land to the west of the
existing site, occupied by the Bancroft Rugby Club, was also deemed unsuitable for development
as the site was not large enough to accommodate the proposed facilities and replacement
community/sporting facilities for the rugby club. This was in part due in part to the flood sensitive
nature of the site. The potential options for expanding the existing facilities at Spurs Lodge have
been fully explored by the applicant and the argument for needing to relocate is therefore

27      Sixteen potential relocation sites were identified by the applicant and were selected on the
basis of their size (minimum area of ten hectares to accommodate the necessary built development
and the sports pitches) and their proximity to White Hart Lane (sites needed to be within a radius
of 5-7 mile of White Hart Lane in order to meet Football Association rules governing the maximum
acceptable travelling times for students attending the academy on weekday evenings).

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28      Twelve of the potential relocation sites were Green Belt or Metropolitan Open Land. All of
the sites, except one, were discounted as being unsuitable for a combination of reasons, including:
inadequate size to accommodate all necessary outdoor sports facilities and built development,
flood risk, commercial viability concerns due to the existence of planning permissions for
commercial uses, geotechnical constraints, public access requirements, irregular shape and
topography. Initially the only potentially suitable site was Epping Lane, Abridge, a Green Belt site.

29      The applicant sought planning permission for the development of combined facilities at this
site but this application was refused by Epping Forest District Council in February 2003. As a result
the Club reassessed the development potential of other previously discounted sites. Myddelton
House sports ground was previously considered not to be large enough (on its own) to
accommodate the development and it was also affected by a requirement by Middlesex University
for shared-use of any facilities to be developed there. By the time of the current application the
University’s requirements had changed and additional land (the agricultural land owned by Enfield
Council) was also available, enabling the current application to be put forward.

Strategic planning issues and relevant policies and guidance
30       The relevant issues and corresponding policies are as follows:

•    Loss of Green Belt             London Plan; PPG2
•    Impacts on the openness        London Plan; PPG2
•    Sporting facilities            London Plan; PPG17; A sporting future for all
•    Urban design                   London Plan; PPS1
•    Historic Environment           London Plan; PPG15
•    Access                         London Plan; PPS1; SPG “Accessible London: achieving an
                                    inclusive environment”; ODPM Planning and Access GPG
• Sustainable development           London Plan; PPS1, PPG3; PPG13; PPS22; the Mayor’s Energy
                                    Strategy; SPG Sustainable Design and Construction
• Transport/Parking                 London Plan; the Mayor’s Transport Strategy; PPG13

31     For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the
development plan in force for the area is the Enfield Unitary Development Plan (1994) together
with the 2004 London Plan. There are also some interim amendments to the UDP (published in
1997 and 1999) that are material considerations.

Loss of Green Belt
32      Planning Policy Guidance Note 2 (PPG2) states that there are five purposes for the
inclusion of land within the Green Belt. These are: to check the unrestricted sprawl of large
built-up areas; to prevent neighbouring towns from merging into one another; to assist in
safeguarding the countryside from encroachment; to preserve the setting and special character
of historic towns; and to assist in urban regeneration by encouraging the recycling of derelict
and other urban land. Once Green Belt land has been defined, PPG2 states that the use of land
within it has a role to play in fulfilling a number of different objectives, including the provision of
opportunities for outdoor sport and recreation. Paragraph 1.7 of PPG2 notes, however, that
“the purposes of including land in Green Belts are of paramount importance to their continued
protection, and should take precedence over the land use objectives.”

33      The crux of the Green Belt policies contained within PPG2 is twofold. firstly, the
construction of new buildings is inappropriate unless it is for the provision of essential facilities
for outdoor sport and recreation, such as small changing rooms or unobtrusive spectator
accommodation for outdoor sport. Secondly, development should ‘preserve the openness of the

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Green Belt’ and should not conflict with the main purposes of including land within Green Belt.
Policy 3D.8 of the London Plan states that there is a general presumption against inappropriate
development in the Green Belt, and that such development should not be approved except in
very special circumstances.

34      The proposed development would result in the construction of sixteen outdoor sports
pitches. The outdoor pitches and associated landscaped areas would occupy the majority of the
site and “account for over 96% of the land take”. Outdoor sport is an appropriate use of Green
Belt land and this aspect of the proposed development would not conflict with Green Belt policies.

35      The proposed development also includes a number of ‘essential facilities’ associated with
the outdoor sports use of the site, including changing facilities and grounds maintenance and
equipment storage facilities. Whilst these facilities technically also constitute appropriate
development they form a relatively small component (20% or 2,489 sq.m.) of the new built
development and would be contained within the football training centre building that also contains
a number of non-essential facilities. The new football training centre, with a total floor area of
11,799 sq.m. includes a large indoor sports hall for the youth academy (3,710 sq.m.) gymnasia,
medical treatment rooms, dining areas, relaxation areas, classrooms and office accommodation.
Whilst these activities are clearly ancillary to the site’s use as a professional football training facility,
the nature of these uses goes beyond what might reasonably be termed ‘essential facilities’ in
terms of PPG2 and this aspect of the development is therefore considered inappropriate
development. On this basis the applicant needs to make a robust argument that special
circumstances exist to justify the inappropriate development of Green Belt.

36     The very special circumstances argument put forward by the applicant is multi-faceted and
can be summarised as:
    •   The need for the development.
    •   The lack of alternative sites.
    •   The contribution to Green Belt objectives.
    •   The contribution to restoring heritage.
    •   The provision of a community facility.

37      Firstly, the applicant has cited the ‘need’ for the development. The ‘football need’
argument centres around the need for high quality integrated training and support facilities at the
professional level. As professional football becomes ever more competitive, the need to provide
improved facilities that enable a higher level of management and control over all aspects of a
player’s professional sporting life (such as physical fitness training, diet, injury assessment,
treatment and rehabilitation) is acknowledged. The current proposal provides additional facilities
such as hydrotherapy, gymnasia, medical treatment facilities, relaxation and dining areas and
educational facilities all of which would be commensurate with the standard of facilities found at
top-level football clubs throughout England and Europe. In this respect, it has been argued that
the proposed facilities are essential in enabling Tottenham Hotspurs Football Club to remain
competitive within the Premier League, although not ‘essential’ in Green Belt terms.

38      The current proposal combines the academy and first team training facilities on one site.
Since the production of the Football Association Charter for Quality in 1997 nearly every Premier
League club has set up a youth academy, and this is now an expected element of the operation of
all clubs at this level. The existing academy facilities are sub-standard and do not meet the
licensing requirements of the Football Association. The operation of the academy from separate
sites, with inadequate facilities, would not be in the best interests of the overall education and
welfare of the students and, would not be a sustainable solution, particularly in terms of minimising

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the need to travel. The applicant has confirmed that the Club will lose its temporary/transitional
license unless facilities that meet the Charter can be found soon. Whilst the loss of an academy
license would not directly affect the status of the first or reserve teams the Club would be unable
to compete with other clubs to attract and retain young talented players. This would have a knock
on effect as there would be a lack of young players to supply the first and reserve teams and may
ultimately affect the Premier League status of the Club.

39       The need for the new facilities is accepted as it is acknowledged that the existing facilities
available to the club are limited and that professional football requires the provision of dedicated
and ever more sophisticated training facilities in order to compete effectively at national and
international levels. It is also acknowledged that the academy facilities are an essential ‘piece of
the puzzle’ for the overall development strategy of the Club and its long-term success in the
Premier League. The contribution that Premier League football clubs, such as Tottenham Hotspur
makes to promotion of football as England’s national game is also presented in the application. A
number of recent planning decisions have been cited within the application in which the Planning
Inspectorate or the Secretary of State accept the contribution that professional football training
facility makes to the development of football nationally and regionally, benefiting professional
players and young people, as constituting very special circumstances.

40      The ‘need’ argument would not, if viewed in isolation, constitute very special circumstances
without supporting evidence to demonstrate that no suitable alternative sites are available. The
applicant has submitted an assessment that demonstrates no suitable alternative sites are available
for development within a realistic timeframe. It is difficult to test the robustness of the information
submitted without commissioning a peer review of the findings for each site and commissioning a
separate site survey, but the information appears comprehensive. It is also worth noting that the
majority of potentially suitable sites identified by the applicant were also located within the Green
Belt or on Metropolitan Open Land. This may be a result of the large land take necessary to
accommodate the built development and the sports pitches and may also be due to the
predominantly ‘green’ appearance and character of the proposal (i.e. the sports pitches).

41      The special circumstances argument put forward by the applicant includes recognition of
the contribution the development would have towards meeting one of the basic Green Belt
objectives, providing opportunities for outdoor sport and outdoor recreation. The proposal would
meet this objective as it provides sports training facilities for both professional footballers and
emerging young players, via the academy facilities. In addition, the application also proposes to
allow limited community use of the facilities.

42       Community access would be implemented and managed through the establishment of a
‘Community Football Partnership’ (comprising Club representatives, the Tottenham Hotspur
Foundation and Enfield Council). The draft S.106 agreement secures community access to the
facilities for a period of time equivalent to twenty hours per week. The draft S.106 also commits to
creating and maintaining a community based programme (to achieve the following objectives:
improved health, through increased levels of exercise; encouraging healthy eating; crime diversion,
through increased activities to divert children away from crime; community development, through
maximising the number of trained sports coaches, administrators, officials etc; and wider
educational objectives to increase pupil achievement and inclusion) for a period of five years.

43      These commitments are welcomed and could work well if the Community Football
Partnership has the necessary resources to put towards formulating a programme of activities, but
there is some concern regarding its deliverability. The success of the community programme is
largely dependent upon the formation of a strong partnership between the Club and Enfield
Council and it is not known whether dedicated human resources are available within Enfield Council
to apply to this task. There is also concern regarding what mechanisms will be put in place to
ensure that community access to the building is effectively managed and monitored, particularly

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given the strong demands placed on the building as a professional training facility. Additional
information is required to demonstrate how community access to the facility will be managed and
maintained on an ongoing basis.

44      In addition to community access to the football training centre the original application also
proposed a new, dedicated community sports hall on a separate site on the eastern side of Bulls
Cross Road. This constituted a significant financial commitment on the part of the applicant but
due to objections from the community regarding its location in the Green Belt, this element of the
proposal was removed from the application. The amended application fails to deliver the same
package of community benefits that the original application would have delivered and a more
tangible commitment is sought.

45      Enfield Council and the applicant are currently discussing the potential for them to
contribute towards the renovation of an existing community facility in Enfield. These discussions
are in the early stages but it would be appropriate for Enfield to seek a financial contribution to put
towards development of new/replacement community facilities within the borough. The
contribution could be utilised to fund or part-fund physical development works, could be used in
the maintenance of existing facilities or could be put towards employing additional staff at Enfield
Council to work as part of the ‘Community Football Partnership’. An appropriate sum should be
agreed to ensure delivery of wider benefits for the community.

Impacts on the openness of the Green Belt
46       Notwithstanding acceptance of the very special circumstances argument it is also necessary
to demonstrate that the proposal would not impact adversely on the openness of the Green Belt.
Whilst overall the proposed built development occupies a relatively small proportion of the site
(4%) the footprint of the football training centre is large, at approximately 7,738 sq.m. GLA
officers raised concerns regarding the scale and design of the original building. The building has
now been completely redesigned and the building footprint reduced by approximately 300 sq.m.
Clearly the building is still large, but a number of design elements have been introduced to reduce
its visual impact and bulk. The building has been sunk into the ground and the two wings of the
building (surrounding the indoor sports hall) are limited in height to two storeys. The indoor sports
hall, comprising 3, 710 sq.m. of footprint, has been designed to be a transparent, lightweight
structure clad in ETFE (crystal clear Teflon foil), with the aim of reducing the visual bulk of the
building and reducing impacts on the openness of the Green Belt. The ends of the building have
also been designed as the respective entrances to the first team and academy facilities and are clad
in glass enabling views through, again reducing the ‘weight’ of the building.

47       After requests from GLA officers the applicant has researched existing academy and first
team facilities within the UK to provide a benchmark against which the scale of the proposed
facilities can be measured. The information submitted demonstrates that other Premiership clubs
have combined training facilities containing a similar mix of facilities but that the scale of these
facilities varies considerably. The proposed football training centre is at the top end of the
spectrum (in terms of scale) but despite this, the overall design approach is welcomed. The
building is of a high quality design that reflects its use as a sports training facility.

48       Despite a general acceptance for the design approach and the scale of the building, there
remain concerns regarding the extent of development on the site. The proposal provides two
separate parking areas, one for the first team to the north of the building (58 spaces) and a second
for academy players/staff to the west (64 spaces). An additional area of overflow parking (90
spaces) to be formed using structured reinforced grass, is also proposed along the western
boundary. Whilst it is accepted that an element of separation is needed between the academy and
first team facilities for management and security reasons, the proposed layout does not maximise
the potential for shared facilities nor does it minimise the extent of development on site, and is

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unacceptable. Further thought should be given to how the parking could be managed more
effectively thereby negating the need for overflow parking to reduce the visual impact of the
development on the Green Belt.

Sports facilities
49       Policy 3D.5 of the London Plan states that the Mayor will work with strategic partners to
promote and develop London’s sporting facilities. National planning policy recognises that the
promotion of sporting excellence can help to foster civic and national pride. The government has
published a national strategy for sport entitled ‘A sporting future for all’. This document outlines
the government’s aspirations for sport in the United Kingdom and states that it wants to see:
“more people of all ages and all social groups taking part in sport; and more success for our top
competitors and teams in international competitions.” The applicant has confirmed that the
football training centre, as well as providing a world-class training facility for Tottenham Hotspur
first team and academy players, would also provide a facility that is available for use by the public,
via Tottenham Hotspur’s Football in the Community Programme. The development of these
facilities would be consistent with the London Plan policy 3D.5 and with the national sports

50      Furthermore, the proposed development would support London’s role as a world city. The
new facilities are likely to increase the profile of the Club and may enhance its success within the
Premier League due to an enhanced ability to attract and retain top class players. Given the profile
of Premier League football within England and further a-field, the establishment of new world-
class facilities can only enhance the profile of the Club and indirectly, London’s profile, in the
international sporting arena.

51       The design submitted in September 2005 by KSS Design Group was uninspiring and of
insufficient quality to be supported in strategic planning terms. Since then, GLA officers and the
design team have worked together to revise and develop the form and massing of the building
and its relationship to the surrounding landscape. The new structure has been designed to
reduce its impact and visibility from Forty Hall, Myddleton House and adjoining conservation
area. The building will be sunk into the ground to reduce potential skyline conflict and the
existing and proposed hedgerow planting has influenced the site planning, to allow natural
screening to the development.

52      The proposed building will provide an innovative, lightweight contemporary structure.
The building is conceived as two interlocking and overlapping blocks which wrap around the
lightweight transparent covered pitch. The solid end walls to the blocks, combined with a strong
and continuous eaves line, creates a frame within which the training facility is effectively
contained. The reception areas to the academy and first team are located within the block ends
where a high degree of through-building transparency enables views through to the wider
landscape as a continual reference to the existing setting and to the new pitches.
The landscaping water feature creates a clear separation of the first team entrance and facilities
from the rest of the site, physically separating but maintaining views from the academy area and
also reinforcing and reflecting the pavilion design. Planes of natural stone are contained within
the building frames; the stone contrasting in colour, texture, solidity and warmth, from the
adjacent transparent glazed areas; also providing the opportunity for the building character to
change between daytime and evenings. The architectural response and the relationship of the
building to its context is welcomed.

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Historic environment
53      Policy 4B.11 of the London Plan recognises the importance of London’s historic assets and
aims to ensure that these assets are not viewed in isolation and that development respects and
responds appropriately to its historic context. The eastern portion of the site, namely the area
surrounding Myddelton House, lies within the Forty Hill Conservation Area. Surrounding the site
there are also a number of listed buildings including Myddleton House and gardens and Forty Hall
Estate which are included on the English Heritage Register of Parks and Gardens as grade II
Historic Landscapes. The site also lies within the Enfield Chase Heritage Area, designated as an
Area of Special Character (AOSC) in the Enfield Unitary Development Plan.

54      A detailed landscape assessment, visual analysis and conservation appraisal was submitted
with the application. This analysis confirms that the application site is very visually contained due
to the presence of dense trees and hedgerows. The assessment also indicates that as a result of
previous development (including existing sports pitches, tennis courts and a small pavilion building)
the setting of Myddleton House and gardens is already somewhat degraded. The proposed
development provides an opportunity to reinstate elements of the historic landscape and this is
welcome. The proposed removal of the existing pavilion, tennis courts and car parking immediately
west of Myddleton House and the reinstatement of historic hedgerows to reinforce historic field
patterns in keeping with the 1867 OS map would reduce the impact of the proposed buildings and
would enhance the immediate setting of Myddleton House and gardens and its listed buildings.
The delivery of the landscaping proposal contained within the landscape master plan should be
secured by Enfield Council via conditions.

55      The application affects land adjacent to a Site of Importance for Nature Conservation
identified through the adopted procedures for London1. The site concerned is the Forty Hall
Park & Estate Site of Borough Importance, Grade I. This lies immediately to the south of the
proposal site.

56      The applicant has submitted an ecological impact assessment in support of its
application (AMEC Earth & Environmental UK, Ecological Survey and Impact Assessment, Bulls
Cross, Enfield, April 2006). This report is useful in informing the evaluation of the likely
biodiversity impacts resulting from this proposal.

57       The ecological assessment identifies a number of impacts on biodiversity associated with
this application. These include land-take of minor significance, and potential disturbance to
birds and bats. The most serious aspect with respect to birds is the denial of potential breeding
and wintering habitat for two nationally declining species; skylark Alauda arvensis and lapwing
Vanellus vanellus. The potential permanent disturbance of bats and bat roosts is of particular
significance as these are protected under UK and European wildlife legislation (Wildlife &
Countryside Act 1981, as amended and Habitats Regulations 1994).

58       The ecological impact assessment has identified the likely importance of the application
site for up to six species of bats, one of which is nationally very rare (barbastelle Barbastellus
barbastellus). The proposal includes the construction of three floodlit football pitches. The
construction and especially the subsequent use of these could threaten the viability of any bat
roosts within their vicinity. As the ecological impact assessment for bats was undertaken at a

  Policy, criteria and procedures for identifying nature conservation sites in London. Adopted by the Mayor as a firm
basis for the London Biodiversity Strategy. first adopted by the LEC in 1994, by LPAC in 1995, and recommended in
RPG3 in 1996.

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sub-optimal time of year to ascertain the location of actual roosts, further bat surveys are to
take place this summer.

59      This information is critical for assessing the adequacy of the proposed mitigation
strategy in relation to bats. Additional mitigation may be required depending on the findings of
further surveys. Concerning impacts on the two nationally declining birds, the mitigation being
proposed appears to be adequate and achievable.

60      The site is outside the floodplain but has significant surface water run-off issues. Policy
4C.8 of the London Plan seeks to ensure that surface water run-off is managed as close to its
source as possible and promotes the use of sustainable urban drainage systems to achieve this.
Minimising surface water run off is a key strategic issue for this development from two
perspectives. firstly, the need to reduce rainwater entering the local drainage system and
tributary river (Turkey Brook). The proposed all-weather pitches will not absorb water as an
undeveloped greenfield site would do, and buildings will also increase surface water run-off.
Secondly, the grass pitches will require significant amounts of water for irrigation. Retained
surface water can provide such water and reduce the development’s impact on water resources.

61      Section 7.13.3 of the applicant’s Design Statement and the Flood Risk Assessment
promote the use of sustainable urban drainage systems and it is proposed to incorporate the
following measures into the design of the development:

   •   The use of gravity-fed swales to direct rainfall to the irrigation storage facility (adjacent
       to the groundsman’s shed) and the surface water attenuation tanks.
   •   The retention of surface water runoff during the 1 in 100 year flood event to reduce
       peak flows into Turkey Brook and New River to assist in reducing flooding downstream.
   •   The re-use of surface water runoff from the site for irrigation thereby reducing the
       supply of potable water required for the development.

62     These approaches are welcome and are consistent with London Plan policy, and need to
be secured through condition or planning obligation in order to avoid the possibility that this
development will be unsustainable from a water perspective.

Access and inclusion
63       The applicant has provided an access statement to demonstrate how the proposal aims to
promote an inclusive environment. This statement makes a strong commitment to ensuring that
the new building and sports facilities will cater appropriately for all potential users, regardless of
disability, age or gender, and confirms that the initial access statement will be further developed at
the detailed design stage, in coordination with Enfield Council’s access officer. This commitment is
welcome and should be secured by Enfield Council via conditions.

Sustainable development
64      The original application indicated that the applicant would consider implementing
natural ventilation and rainwater harvesting within the scheme along with ground source heating
for the under soil pitch heating system, and the future use of solar hot water panels and
photovoltaic panels. However, these measures had not been considered in detail and there were
no firm commitments to sustainable energy measures. Following a series of discussions with
GLA officers, the scheme has progressed substantially through the revised application, although
there are still outstanding matters.
                                                                                              page 12
65      In terms of energy efficient design, the lack of detailed design work at this stage means
that there is little detail on what energy efficiency measures are incorporated. The statement
indicates that natural ventilation, green roofs and solar shading have been incorporated, but the
lack of detail is disappointing. Enfield Council should secure a condition to ensure that a
detailed statement is submitted prior to commencement of development outlining the specific
energy efficient design measures incorporated and the extent to which they reduce likely carbon
dioxide emissions.

66      There are two potential options for renewable energy proposed by the applicant, subject
to completion of further work. These are either; a combined heat and power system with
ground source heat pumps to provide under soil heating, and cooling to the buildings, or a tri-
generation system (combined cooling, heating and power) complemented by a biomass boiler.
The CHP + ground source heat pumps will reduce carbon emissions by 5% and 10% respectively,
whilst the tri-generation system requires detailed work to ensure that at it can be sized
accurately, given the relatively unique usage of the building. The biomass boiler will also deliver
a 10% reduction in carbon emissions. The applicant has been asked to demonstrate that the tri-
generation system with biomass can be physically incorporated into the scheme, and this
information is expected soon.

67      Both proposals are consistent in principle with policies 4A.7 and 4A.8 of the London Plan
and will result in carbon dioxide savings against the baseline scheme.

68      To allow necessary technical work to be carried out through the detailed design process,
Enfield Council should impose the following conditions:

    •   Prior to the commencement of development the applicant should submit details to be
        approved in writing by the local planning authority of the proposed energy efficiency
        and renewable energy measures consistent with the agreed strategy to incorporate either
        combined heat and power plant and associated infrastructure with the ground source
        heat pumps, or the tri-generation plant and associated infrastructure with the biomass
        boiler. These measures should be implemented and retained thereafter unless otherwise
        agreed with the local planning authority.

    •   The applicant should demonstrate the carbon dioxide savings from the energy efficiency
        measures and demonstrate that the renewable energy technologies reduce carbon
        emissions by at least 10%. The applicant should also demonstrate that the power heating
        and cooling infrastructure is incorporated.

Transport for London
65       The site is located to the east of the A10, on the edge of Enfield’s Green Belt. The site
is virtually inaccessible by public transport and as a result it has a public transport accessibility
level of 0.

66     The Transport Assessment states that the site is within 500m of Turkey Street Station.
However, the walking route is on the very edge of the average access distance and beyond for
the majority of the site. Much of the route is a relatively poor environment for pedestrians. Two
bus routes (217 and 317) can be accessed from the A10 but these are outside an acceptable
walking distance from the site.

67     At present TfL cannot support the claim that the proposed development will not have an
unacceptable impact on the Transport for London Road Network from the information provided.

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TfL requires the developer to assess the impact of the proposed development on the A10 Bulls
Moor Lane junction in line with TfL modelling guidelines.

68       TfL is concerned that the documents submitted in support of this application contain
contradictions regarding parking provision. TfL require the developer to confirm the parking
provision for the proposed development as the provisions differ in the transport assessment,
design statement and the plans. It should be noted that TfL regard all levels of parking stated in
the submitted documents to be excessive. TfL believes that the transport assessment does not
fully justify or make best use of the car parking proposed. Parking standards for both non-
residential and leisure uses should be assessed on an individual bases with the use of a transport
assessment as highlighted in the London Plan.

69      TfL is also concerned that the outline Travel Plan for the training facility submitted as
part of the Transport Assessment does not contain sufficient information to ensure the
reduction in travel to and from the training facility by unsustainable means. TfL can assist the
applicant to ensure a robust and effective travel plan is produced. With this in mind, TfL would
also welcome a contribution towards improvements for cycling along the A10 in line with the
London Cycle Design Standards (2005).

London Development Agency
69     The LDA has no comment on this application.

Local planning authority’s position
70     The local planning authority’s recommendation is not known.

Legal considerations
71      Under the arrangements set out in article 3 of the Town and Country Planning (Mayor of
London) Order 2000 the Mayor has an opportunity to make representations to Enfield Council at
this stage. If the Council subsequently resolves to grant planning permission, it must allow the
Mayor an opportunity to decide whether to direct it to refuse planning permission. There is no
obligation at this present stage for the Mayor to indicate his intentions regarding a possible
direction, and no such decision should be inferred from the Mayor’s comments unless specifically

Financial considerations
72     There are no financial considerations at this stage.

73     The proposal will further the development of football at a national level by providing
Tottenham Hotspur with training facilities that will enable the club to compete with other Premier
League clubs within the UK. This support for exemplary sporting facilities is consistent with the
government’s national strategy for sport (“A sporting future for all”) and with policy 3D.5 of the
London Plan.

74     The very special circumstances argument put forward by the applicant comprises the
‘football need’ for the new facilities, the extensive search undertaken for alternative sites, the
benefits of the scheme in enabling the reinstatement of historic hedgerows around Myddleton
House, and local benefits to the wider community through access to the new facilities and the

                                                                                             page 14
implementation of the Club’s community programme. It is essential that these community benefits
are deliverable and despite a commitment to provide public access to the facilities for the
equivalent of twenty hours per week there remain questions regarding how this will be managed,
particularly in light of the strong demands placed on the new facilities by the professional
footballers and academy players. Whilst this commitment is very welcome and needs to be secured
within the S.106, a more tangible proposal to deliver a more comprehensive package of community
benefits should be sought by Enfield Council. A financial contribution to be put towards enabling
enhancement of existing community facilities, funding necessary maintenance works or operational
costs, or funding additional staff to enable delivery of the extensive community based programme
via the Community Football Partnership should be secured.

75      A detailed visual assessment of the development, including photomontages and an analysis
of views into the site, has been undertaken and due to the high degree of visual containment,
including screening afforded by the dense trees and hedgerows, the proposal would not be visually
intrusive. Notwithstanding general acceptance of the overall building design there remain concerns
regarding the level of parking proposed and the need to segregate the first team and the academy
player parking areas. Further thought should be given to how the parking could be managed more
effectively thereby negating the need for overflow parking, thereby reducing the visual impact of
development on the Green Belt.

76       The site is inaccessible by public transport and in order to justify development in this
location the scheme should be designed and managed to deliver an exceptional travel plan which
encourages the use of alternative, more sustainable methods of transport to and from the site.
Substantial on-site parking is proposed which conflicts with this objective and the argument
justifying the need for overflow parking is not accepted. Further thought should be given to the
efficient management and dual use of the proposed permanent parking provision to negate the
need for the overflow parking.

77      The scheme has been revised following discussion with GLA officers and has improved
substantially. A condition is sought to ensure energy efficient design measures will be
incorporated, as there is limited information on the detailed design of the building at this stage.
Two sustainable energy options are proposed, both of which are consistent, in principle, with the
London Plan energy policies and will deliver decentralised energy generation from either combined
heat and power or tri-generation and 10% from renewable energy technologies. These also need
to be secured via condition.

for further information, contact Planning Decisions Unit:
Giles Dolphin, Head of Planning Decisions
020 7983 4271 email
Colin Wilson, Strategic Planning Manager (Development Decisions)
020 7983 4783 email
Lee Ogilvie, Case Officer
020 7983 4433 email

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